Indiana Area Foundation of the United Methodist Church, Inc. v. Snyder, 2011 Ind. App. LEXIS 1643

Snyder was appointed pastor of Bloomfield United Methodist Church in 2004; the Board of the Ordained Ministry and church leaders included Reverend Ostermeier and Bishop Coyner.
In 2006, Snyder met with Julie Martin after a complaint; Snyder alleges he was drugged and later memory loss occurred.
The Board placed Snyder on study/renewal leave in 2006; a formal intra-church complaint followed in 2006 and a ninety-day suspension with mandatory psychological evaluation.
In 2007 Snyder chose involuntary leave; he was required to undergo medical and psychiatric evaluation and treatment.
From 2008 to 2009 the church disclosed Snyder’s status to parishioners and the Bloomfield Church responded to inquiries.
Snyder filed suit in 2008 alleging breach of contract and defamation; the trial court later granted partial summary judgment and certified for interlocutory appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Appellants were entitled to summary judgment on defamation.	Snyder argues statements about his fitness to minister were defamatory.	Appellants claim church autonomy shields them from civil review of ecclesiastical statements.	Defamation claim must be evaluated under First Amendment church autonomy; there are facts supporting entitlement to summary judgment for Appellants.
Whether there was an enforceable contract to breach for Snyder under The Book of Discipline.	Snyder contends The Book of Discipline created an enforceable contract with alleged breaches.	Resolution requires interpretation of religious doctrine; court should not adjudicate under First Amendment.	No enforceable civil contract without excessive entanglement; summary judgment on breach of contract affirmed.

Brazauskas v. Fort Wayne-South Bend Diocese, Inc., 796 N.E.2d 286 (Ind. 2003) (church autonomy/defamation context; First Amendment limitations on review of ecclesiastical decisions)
Brazauskas v. Fort Wayne-South Bend Diocese, Inc., 714 N.E.2d 253 (Ind.Ct.App. 1999) (initial decision on defamation and church governance; entanglement concerns)
McEnroy v. St. Meinrad School of Theology, 713 N.E.2d 334 (Ind.Ct.App. 1999) (neutral principles; First Amendment limits on court interference in religious doctrine)
Bryce v. Episcopal Church in the Diocese of Colorado, 289 F.3d 648 (10th Cir. 2002) (organization autonomy and employment decisions in religious institutions)
Rayburn v. General Conference of Seventh-Day Adventists, 772 F.2d 1164 (4th Cir. 1985) (ministerial exception and church governance)